In the Interest of N. P., a Child (Mother)

CourtCourt of Appeals of Georgia
DecidedApril 22, 2022
DocketA22A0583
StatusPublished

This text of In the Interest of N. P., a Child (Mother) (In the Interest of N. P., a Child (Mother)) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Interest of N. P., a Child (Mother), (Ga. Ct. App. 2022).

Opinion

THIRD DIVISION DOYLE, P. J., REESE, J., and SENIOR APPELLATE JUDGE PHIPPS

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

April 22, 2022

In the Court of Appeals of Georgia A22A0583. IN THE INTEREST OF N. P., a child.

PHIPPS, Senior Appellate Judge.

The mother of minor child N. P. appeals from the juvenile court’s order

terminating her parental rights. She argues on appeal that: (i) the juvenile court erred

by conducting the termination hearing via video conference over her objections; and

(ii) the evidence is insufficient to support the court’s findings regarding the likelihood

of future harm to N. P. if the mother’s parental rights are not terminated. For the

reasons that follow, we disagree with both contentions and affirm.

N. P. was born in February 2018. Her father’s whereabouts are unknown. In

January 2019, following an anonymous referral to the Department of Family and

Children Services (“DFCS” or the “Department”) involving concerns for N. P.’s

safety and her mother’s mental health, the child was placed into DFCS custody. At that time, the juvenile court based its initial protective custody order on: (i) findings

that the mother had unresolved mental health issues, including bipolar disorder;

(ii) reports that “spirits were telling her to kill her child”; (iii) the mother’s inadequate

housing, lack of electricity, and “minimal” food in her home; and (iv) her refusal to

cooperate with the Department’s attempts to implement a safety plan. When N. P.

entered DFCS custody, she had “excessive” eczema, matted hair, and dirty

fingernails; lacked vaccinations; and “appeared to be very much underweight,” with

“sagging skin” and dark circles around her eyes. Assessments performed around the

time of N. P.’s removal revealed delays in expressive communication; sensory issues;

an inability to self-calm; and concerns with tactile sensitivity, possibly due to trauma,

including a dislike of being dressed or bathed and having her hair brushed or nails

cut.

During a February 2019 adjudicatory hearing, the mother admitted that she

experienced “hallucinations and blurry-like visions” but denied any mental health

issues other than anxiety and attention-deficit / hyperactivity disorder. Based on

testimony from a family violence center advocate, a friend of the mother, and the

child’s maternal grandmother regarding schizophrenia in the mother’s family and

various unusual behaviors by the mother — including reports that unidentified beings

2 were urging the mother to kill her “evil” baby — the juvenile court again found that

the mother had unresolved mental health issues. The court also found that N. P.

remained severely underweight and developmentally delayed, that her eczema had not

yet resolved, and that she had multiple self-inflicted scabs due to scratching.

Consequently, the juvenile court adjudicated N. P. dependent due to abuse and

neglect, ordered the mother to submit to a psychological and fitness evaluation, again

awarded temporary custody of the child to DFCS, and allowed the mother supervised

visitation.

Also around that time, Dr. Jacquelyn Zahm, a psychologist, examined the

mother and diagnosed her with bipolar disorder with psychotic features, for which

Dr. Zahm recommended psychiatric treatment (to assess potential medication

management) and intensive therapy. During a May 2019 dispositional hearing,

Dr. Zahm testified that the mother had “experienced prolonged periods of sleep

deprivation,” as well as “command hallucinations” to harm herself and her child, and

had “demonstrated a tendency where she feels strongly compelled to act upon the

commands presented by the voices that she hears.” Dr. Zahm opined that the mother’s

struggles put N. P. “at significant risk for maltreatment until the mother makes

3 progress in mental health treatment to manage her diagnosis” and, on that basis,

recommended that the mother’s visitation with N. P. be supervised.

In a dispositional order entered following the May 2019 hearing, the juvenile

court found that the mother continued to deny any mental health issues and that N. P.

remained dependent due to those issues and the mother’s medical neglect of the child

(as detailed in its prior order). Consequently, the court continued the child’s

placement with DFCS and again allowed the mother supervised visitation. The court

also ordered DFCS to prepare a case plan for reunification, to consist of several goals

for the mother, including: (i) demonstrating an ability to meet the child’s basic and

medical needs; (ii) participating in parent aide services, following recommendations,

and demonstrating the skills learned; and (iii) addressing her own mental health needs

and following all of Dr. Zahm’s recommendations, including submitting to a

psychiatric evaluation for medication management, participating in intensive

individual therapy, and following the recommendations that resulted from each. A

case plan to that effect was entered in May 2019.

Following a June 2019 hearing, the juvenile court entered an “Initial Judicial

Review Order” in which it again continued the child’s placement with DFCS and

allowed the mother to continue visitation. (Capitalization omitted.) Based on

4 evidence presented at the hearing, the court found that N. P. was doing well in her

foster-home placement and was showing reduced tactile hypersensitivity and

improved motor and social skills. The child’s immunizations and wellness checks

were up-to-date, she had gained weight, and her eczema was improving.

The court further found that the mother had submitted to psychological,

parental fitness, and domestic violence evaluations by Dr. Zahm. While the mother

also had participated in two individual counseling sessions with a therapist, she

nevertheless continued to deny “any history, or current symptoms, relating to her

mental health.” The mother at that time resided in housing obtained through a county

family violence center and had not provided proof of employment. The juvenile court

determined that, while the mother was “making progress,” the child nevertheless

remained dependent, as the mother needed “to continue mental health and parenting

services” and remained “unable to adequately meet the needs of the child.”

Following an October 2019 permanency hearing, the juvenile court found that

the mother continued to make progress on her case plan and was participating in

individual counseling and parent aide services. And due to positive reports from

providers, the mother had begun unsupervised visits with N. P. Nevertheless, the

court again continued the child’s placement with DFCS to allow the mother to

5 continue mental health and parenting services needed to address the child’s ongoing

dependency.

The unsupervised visitation continued for only one month. As a result of parent

aide reports that the mother’s apartment lacked electricity and that she had engaged

in multiple questionable behaviors, her visits with N. P. were required to be

supervised again starting in November 2019, following a panel review hearing. DFCS

petitioned to terminate the mother’s parental rights in August 2020.

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In the Interest of N. P., a Child (Mother), Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-the-interest-of-n-p-a-child-mother-gactapp-2022.